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HomeMy WebLinkAboutA007 - Memo submitting proposed flood plain ordinance to Planning City of Ames M E M O R A N D U M T0: Ron Wooldridge, Chief Planner FROM: John R. Klaus , City Attorne w,_, DATE: November 19, 1979 SUBJECT: Flood Plain Zoning Ordinance In response to your memorandum of November 7 , I have as you requested, read the proposed flood plain zoning ordinance- -- - which will be submitted and considered by the City Council at its meeting of November 20. I have no objection to any of the substantive provisions of this ordinance. As for legal matters , the ordinance is for the most part in good form. I do have certain technical comments to make, however, as follows : 1. Section VIII, A(1) could be interpreted as creating the position of "Chief Building- official" to be appointed by the City Council and directly responsible to City Council. I don' t believe that that is your intention. Certainly the City Council has , in the past, indicated that they choose to Q have all administrative responsibilities established by ordinance under the City Manager with the City Manager then free to make such delegations as the Manager sees fit to do. Unless you have some specific objection to this , I will in- corporate appropriate changes in this language on the final form of ordinance as drawn up. 2 . Section VIII, C(1) purports to create and provide for the appointment of a Zoning Board of Adjustment . As you C know, the Zoning Board of Adjustment already exists , and this subsection is , therefore, unnecessary. 3. Section VIII, C(4) uses the term "variance" when the proper term is "exception" . The term variance is used throughout this ordinance when the term "exception" is what is , in fact , intended. I believe you appreciate and understand the technical legal difference between vari e OK and an exception. Under Chapter 414 of the Code of Iowa and under the decisions of the Iowa Supreme Court inter- preting this chapter variance is viewed as one of the inherent powers of the Zoning Board of Adjustment regardless of what the City' s ordinance may provide. However, the circumstances under which a variance may be lawfully granted are extremely limited. "Exceptions" , however, are grantable by a Board of Ron Wooldridge 2 November 19, 1979 Adjustment only if the standards and conditions set out in the ordinance by the City Council are met. The courts have stated that the common device known as the special use permit , condi- tional use, or special exception use is simply one form of the gard, I invite your attention to my exception. In this re Legal Opinion No. 2 addressed to you under date of September 15, 1972 . 4. Section XI on page 15 purports to prohibit future city councils from legislating any amendment to the flood plain zoning regulations without the prior permission of the Iowa Natural Resources Council . That prohibition against the legislative powers of the City Council is void as a matter of law and totally inappropriate to this ordinance. If the Iowa Natural Resources Council is stating that any amendment to the ordinance by the City Council will jeopardize federal flood insurance unless the amendments are first reviewed by the Iowa Natural Resources Council and found to be acceptable, this is something that the Iowa Natural- Resources Council can explain to the City Council by letter or rule. It is not something, however , that belongs in the City' s zoning ordinance. cc T.V. Sprenkel Encl.